Justia Civil Rights Opinion Summaries

A man was accused of sexually abusing a minor, referred to as Jane Doe, based on allegations that surfaced in 2018 and 2019. Initially, the police received a referral from Child Protective Services after Doe made statements to a suicide hotline about being abused by her “father’s friend.” The case was closed when Doe refused to discuss the allegations. In 2019, after another suicide attempt, Doe identified the man by name during therapy, and this information was relayed to the police. Detective Thorsdottir conducted a forensic interview with Doe, who provided detailed accounts of abuse and identified the accused. The investigation included interviews with Doe’s parents and therapists, surveillance, and searches of the accused’s home, which yielded a handgun but no evidence of child pornography. The accused was arrested and indicted, but the charges were later dropped after new evidence suggested Doe had previously identified a different individual as her abuser.The accused filed a civil suit in Virginia state court, later removed to the United States District Court for the Eastern District of Virginia, alleging malicious prosecution under both state law and the Fourth Amendment. The district court dismissed the complaint under Rule 12(b)(6), finding that the plaintiff failed to plausibly allege a lack of probable cause for his arrest and prosecution, and that the detective was entitled to qualified immunity on the federal claim.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that the complaint and its exhibits did not plausibly allege that the detective acted with deliberate or reckless disregard for the truth, nor that she omitted material facts necessary to negate probable cause. The court concluded that probable cause existed based on Doe’s identification and corroborating evidence, and affirmed the district court’s dismissal of both the federal and state malicious prosecution claims. View "Moretti v. Thorsdottir" on Justia Law

Shawn Otis Hernandez was convicted by a jury of conspiracy to commit first degree residential burglary and attempted first degree residential burglary, following an incident in which multiple individuals attempted to break into a home late at night. Evidence against Hernandez included cell phone records, home security video, DNA analysis, and a prior conviction for a similar crime. During jury selection, the prosecution exercised several peremptory challenges against jurors under the age of 25, prompting Hernandez to object on the basis that these challenges were discriminatory.The Ventura County Superior Court reviewed Hernandez’s objection under Code of Civil Procedure section 231.7, which prohibits discrimination in jury selection based on certain protected categories. The trial court found that the prosecution’s reasons for excusing the young jurors were valid and supported by the record, and that age was not a substantial factor in the use of peremptory challenges. The court also noted that neither party raised objections based on ethnicity or gender during trial, and that the empaneled jury included several males and individuals with Spanish surnames.The California Court of Appeal, Second Appellate District, Division Six, affirmed the judgment. The court held that youth alone is not a cognizable group under section 231.7, and neither Batson v. Kentucky nor Wheeler prohibits excusing jurors solely based on youth. The court further held that objections to the dismissal of jurors based on protected class membership under section 231.7 must be made in the trial court, or the claim is forfeited on appeal. Hernandez’s claims regarding ethnicity and gender were deemed forfeited, and his ineffective assistance of counsel claim was rejected due to lack of deficient performance and prejudice. The judgment was affirmed. View "People v. Hernandez" on Justia Law

A police officer with the Metropolitan Police Department in Washington, D.C., was involved in two separate incidents within five days, during which he used neck restraints—specifically, trachea and carotid artery holds—on two individuals while on duty. Both incidents occurred at McDonald’s restaurants, and in each case, the officer initiated physical contact and applied prohibited neck restraints, despite the individuals not posing an immediate threat or actively resisting arrest. The officer was aware that such holds were forbidden by department policy, and in one instance, had been warned about his conduct just days before repeating it.A grand jury indicted the officer on five charges related to these events. Before trial, three charges were dropped. The United States District Court for the District of Columbia conducted a jury trial, after which the officer was convicted on two counts of depriving individuals of their rights under color of law, in violation of 18 U.S.C. § 242. The jury found that the officer acted willfully, used excessive force, and caused bodily injury. The court sentenced him to concurrent six-month prison terms and supervised release. The officer moved for acquittal and a new trial, arguing, among other things, that the jury instructions on willfulness were improper and that the evidence was insufficient. The District Court denied these motions.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the officer’s challenges. The court held that the jury instructions on willfulness were not plainly erroneous, as precedent allows conviction under § 242 for conduct done in reckless disregard of constitutional rights. The court also found sufficient evidence supported the jury’s findings of excessive force and willfulness, and that no impermissible amendment or variance of the indictment occurred. The appellate court affirmed the District Court’s evidentiary rulings and the officer’s convictions. View "USA v. Clark" on Justia Law

Marian Hudak was charged with two federal hate crimes after separate assaults on two men in North Carolina. The first victim, J.D., was a Mexican-American neighbor whom Hudak had repeatedly harassed with racial slurs and threats, culminating in a physical attack. The second victim, J.S., was a Black man whom Hudak confronted in traffic, using racial epithets and threats, and physically attacked his vehicle before chasing him to his apartment complex and threatening further violence. Evidence showed Hudak possessed Nazi and Ku Klux Klan memorabilia and had a history of expressing racist views.The United States District Court for the Middle District of North Carolina presided over Hudak’s trial. The government presented evidence of Hudak’s racist motives, including testimony about his Nazi memorabilia and prior racist conduct. Hudak conceded intent to injure and intimidate but argued his actions were due to road rage and mental illness, not racial animus. The district court excluded expert testimony about Hudak’s mental illness, finding it unreliable and irrelevant under Federal Rule of Evidence 702 and the Insanity Defense Reform Act, since Hudak did not plead insanity. The court also admitted evidence of Nazi memorabilia after Hudak testified about his interest in military history, determining he had “opened the door” to its relevance.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s evidentiary rulings for abuse of discretion. The Fourth Circuit held that the district court properly excluded the mental health evidence and correctly admitted the Nazi memorabilia after Hudak’s own testimony. The court affirmed the jury’s verdict, holding that the government only needed to prove the victims’ race or national origin was a but-for cause of the assaults, and that Hudak received a fair trial. The judgment of the district court was affirmed. View "United States v. Hudak" on Justia Law

A man was charged in 2002 with multiple sexual offenses involving three minor males. In 2003, he entered a plea agreement, pleading no contest to several counts of committing lewd acts on children aged 14 or 15 and one count of oral copulation with a victim under 16, which was amended from a charge of forcible oral copulation to a nonforcible offense. He did not admit to using force or violence in his plea, but the factual basis for the plea referenced police reports describing acts involving force. He was sentenced to state prison in accordance with the plea agreement.In 2005, two psychologists evaluated him for commitment as a Mentally Disordered Offender (MDO) under California Penal Code section 2962. A chief forensic psychiatrist certified that he met the criteria, including having committed a crime involving force or violence, based on documentary evidence such as probation and police reports. The Board of Parole Hearings affirmed the certification. He did not challenge the certification in superior court at that time. He remained in custody under annual recommitment petitions, and his only prior challenge was an unsuccessful appeal of a 2022 recommitment order.After that, he filed a habeas corpus petition in Fresno County Superior Court in 2023, arguing that his conviction did not qualify as an MDO offense and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is a proper vehicle to challenge an initial MDO certification based on static factors, even years later. The court found that the evidence was sufficient under the law at the time of certification, and that subsequent changes in evidentiary standards were not retroactive. The court also found no ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

A member of the Lowell police department’s gang unit created an undercover Snapchat account using a “nonwhite” username and bitmoji, aiming to monitor gang activity by befriending users connected to other officers’ undercover accounts. The officer became “friends” with a user believed to be the defendant, though he did not know the user’s identity or race at the time. The defendant posted a video of himself discharging a firearm from a car, which led police to identify and locate him. A search of the defendant’s vehicle uncovered a firearm matching the one in the video and shell casings consistent with those found at the scene. The defendant did not possess a license to carry a firearm.The Lowell Division of the District Court Department charged the defendant with multiple firearms offenses. The defendant sought discovery on a selective enforcement claim, and the court ordered the production of relevant police records and policies. The records showed that all suspects charged from Snapchat investigations with identifiable race were nonwhite. The defendant moved to suppress evidence, arguing racial motivation in the investigation, but a District Court judge denied the motion, finding no reasonable inference of racial motivation. The defendant also moved to dismiss the firearms charges, claiming the resident firearm licensing scheme violated the Second Amendment. Another District Court judge denied this motion, finding the problematic provision severable. The defendant entered conditional guilty pleas, reserving his right to appeal.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant had raised a reasonable inference of selective enforcement under the Commonwealth v. Long framework and remanded for an evidentiary hearing, requiring the Commonwealth to rebut the inference with a race-neutral reason. The court also held that the Commonwealth’s resident firearm licensing scheme was not facially unconstitutional under the Second Amendment, affirming the denial of the motion to dismiss. View "Commonwealth v. Rodriguez" on Justia Law

In 1996, the defendant broke into a home, raped a woman at knifepoint, and carried a child at knifepoint while stealing a firearm and ammunition. He was charged with multiple offenses, including kidnapping to commit robbery and, later, a one-strike rape allegation. After a mistrial due to a deadlocked jury and the emergence of DNA evidence linking him to the crime, the defendant pled guilty in 1998 to several charges under a plea agreement. The plea resulted in the dismissal of the rape charge and the one-strike allegation, and the kidnapping charge was amended. He was sentenced to a determinate prison term, which was later reduced.In 2024, the defendant, who is ethnically Samoan, filed a motion in the Superior Court of Riverside County seeking discovery under the Racial Justice Act (RJA). He argued that the addition of the one-strike allegation before trial was racially motivated, citing a different case involving a white defendant who was not similarly charged. He requested records of comparable cases, including defendants’ races and charges. The People opposed, arguing that the plea negotiations were driven by DNA evidence, not the added charge, and that the comparison case was not analogous. The trial court granted the discovery motion but limited the scope of the records to be produced.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case on a petition for writ of mandate. The appellate court held that the defendant failed to establish good cause for discovery under the RJA because his factual scenario was not plausible in light of the record, the comparison case did not support an inference of racial disparity, and statewide incarceration statistics did not provide specific facts of misconduct in his case. The court granted the writ, directing the trial court to vacate its order granting discovery and to deny the motion. View "People v. Superior Ct. (Lalo)" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

In this case, the appellant was convicted of simple assault with a bias enhancement after an incident at a Metro station. The government’s evidence showed that the appellant approached a group, made derogatory remarks about their sexual orientation, and physically assaulted one of them multiple times. The assailant was later apprehended at a different Metro station and identified as the appellant. The charges were eventually narrowed to simple assault with a bias enhancement, and the appellant was found guilty by a jury.Prior to trial in the Superior Court of the District of Columbia, the appellant objected to the composition of the jury venire, arguing that it did not reflect a fair cross-section of the community, as only three of fifty-four potential jurors appeared to be African American. The trial judge denied the motion to strike the panel, finding that the appellant had not shown systematic exclusion of a group from the jury selection process. The judge also denied a subsequent, untimely request for access to jury selection records, reasoning that the request came only after the motion to strike had been denied and that no prior efforts had been made to obtain such records.On appeal, the District of Columbia Court of Appeals reviewed the sufficiency of the evidence and the fair cross-section claim. The court held that there was sufficient evidence for a reasonable juror to find the appellant guilty beyond a reasonable doubt, based on the testimony of the arresting officer and the circumstances of the arrest. The court also held that the trial court did not err in denying the motion to strike the jury panel or the belated request for jury selection records, finding that the denial was based on the untimeliness of the request rather than an improper threshold requirement. The judgment of the Superior Court was affirmed. View "Brown v. United States" on Justia Law

A Black defendant was convicted of multiple felonies, including attempted premeditated murder, torture, and assault, after a series of violent incidents. The most serious event occurred at a hotel, where the defendant attacked a night manager with a boxcutter, stabbed him, and then continued to assault him with a pen and by biting and headbutting him. The defendant also assaulted correctional officers on two separate occasions while in jail. At trial, the defense did not dispute the violent conduct but argued that the defendant lacked the specific intent required for the most serious charges, emphasizing his impulsive behavior and likening his actions to those of an animal.The case was tried in the San Mateo County Superior Court, where the jury found the defendant guilty on all charges presented. The court imposed consecutive sentences for attempted murder and torture, finding that the crimes involved separate acts of violence and objectives. The court also described the defendant’s conduct as “animalistic” at sentencing. The defendant appealed, arguing that his counsel’s and the court’s animal comparisons violated the California Racial Justice Act of 2020 (RJA), that the court erred in evidentiary rulings and sentencing, and that cumulative error deprived him of a fair trial.The California Court of Appeal, First Appellate District, Division Two, held that the defendant was procedurally barred from raising RJA claims based on his counsel’s animal comparisons because those statements were part of a deliberate defense strategy, invoking the doctrine of invited error. The court also found that the RJA claim regarding the trial court’s comment was forfeited due to lack of objection. The court rejected the defendant’s other claims, finding no evidentiary or sentencing error, and affirmed the judgment. View "People v. Midell" on Justia Law